e a grand jury as a basis for an indictment for perjury.[37] A
corporation may challenge an order for the production of records if it
is unreasonable on grounds other than self incrimination, i.e., if it is
too sweeping,[38] if the information sought is not relevant to any
lawful inquiry,[39] or if it represents "a fishing expedition" in quest
of evidence of crime.[40] In Oklahoma Press Pub. Co. _v._ Walling,[41]
the question of the protection afforded by the Constitution against the
subpoena of corporate records was thoroughly reviewed. Justice Rutledge
summarized the Court's views in the following words: "* * * the Fifth
Amendment affords no protection by virtue of the self incrimination
provision, whether for the corporation or for its officers; and the
Fourth, if applicable, at the most guards against abuse only by way of
too much indefiniteness or breadth in the things required to be
'particularly described,' if also the inquiry is one the demanding
agency is authorized by law to make and the materials specified are
relevant. The gist of the protection is in the requirement, expressed in
terms, that the disclosure sought shall not be unreasonable. * * * It
is not necessary, as in the case of a warrant, that a specific charge or
complaint of violation of law be pending or that the order be made
pursuant to one. It is enough that the investigation be for a lawfully
authorized purpose, within the power of Congress to command. * * * The
requirement of 'probable cause, supported by oath or affirmation,'
literally applicable in the case of a warrant is satisfied, in that of
an order for production, by the court's determination that the
investigation is authorized by Congress, is for a purpose Congress can
order, and the documents sought are relevant to the inquiry. Beyond this
the requirement of reasonableness, including particularity in
'describing the place to be searched, and the persons or things to be
seized,' also literally applicable to warrant, comes down to
specification of the documents to be produced adequate, but not
excessive, for the purposes of the relevant inquiry."[42]

As a means of enforcing a valid statute, the Government may require any
person subject thereto "to keep a record showing whether he has in fact
complied with it,"[43] and to submit that record to inspection by
government officers.[44] It may also compel the filing of returns
disclosing the amount of tax liability,[45] and of reports under